SANTHANAKRISHNAN SETHUNARAYANAN,MADURAI vs. ITO, NCC-1,, MADURAI

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ITA 790/CHNY/2026Status: DisposedITAT Chennai08 June 2026AY 2020-213 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal granted the assessee one more opportunity to produce necessary details regarding the creditworthiness and genuineness of the parties from whom the funds were received. The appeal was remitted back to the CIT(A) for fresh adjudication.

What were the facts?

The assessee deposited a significant sum of cash into their bank account. The Assessing Officer treated this amount as unexplained income. The assessee claimed it was a loan for their father's medical treatment, later converted to a gift due to financial difficulties.

What were the issues?

Whether the cash deposits into the bank account were genuine loans or unexplained income, and if the assessee provided sufficient evidence to substantiate the creditworthiness of the lenders.

Which sections of the Income-tax Act were involved?

Section 148,Section 69A,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI SS VISWANETHRA RAVI & MS. PADMAVATHY.S

For Respondent: Mr. L. Christopher Vasanth, JCIT

आदेश / O R D E R

PER PADMAVATHY.S, A.M: This appeal by the assessee is against the order of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, (in short "CIT(A)") passed u/s. 250 of the Income Tax Act, 1961 (in short "the Act") dated 21.01.2026 for Assessment Year (AY) 2020-21.

2.

The assessee is an individual and filed the return of income on 25.07.2020 declaring total income of Rs.4,97,170/-. The assessee subsequently filed a revised return on 03.08.2020 declaring income at

ITA No.790/Chny/2026 Santhanakrishnan Sethunarayanan :- 2 -: Rs.4,92,230/-. The A.O received information that the assessee has deposited cash amounting to Rs.58,71,500/- into the bank account and therefore had reason to believe that the income chargeable to tax as escaped assessment. Accordingly, the A.O reopened the assessment by issue of notice u/s. 148 of the Act. The assessee submitted before the A.O that the amount deposited is received as loan towards his father's medical treatment from various parties. Since the assessee did not file any further details treated the entire amount as unexplained u/s. 69A of the Act. Before the CIT(A), the assessee reiterated the submissions made before the A.O and also submitted that considering assessee's financial difficulties the parties have subsequently treated the loan amount as gift. The CIT(A) however rejected the submissions of the assessee stating that the assessee has not produced any evidences establishing the creditworthiness of the parities and genuineness is also under question since the assessee has taken different stand with regard to the impugned receipts. The assessee is in appeal before the Tribunal against the order of the CIT(A).

3.

We have heard the parties, and perused the material available on record. The Ld. Authorized Representative (AR) of the assessee during the course of hearing submitted that the assessee had produced the confirmation letters along with PAN details of the parties which substantiates the genuineness of the receipts. With regard to the evidences to prove the creditworthiness of the parties, the Ld. AR prayed for one more opportunity stating that due to the assessee's father's ill-health, the assessee could not submit all details before the lower authorities and the ld. AR also undertook that the relevant details would be submitted without fail if one more opportunity is given. Considering the facts and circumstances peculiar to assessee's case, we are inclined to give one more opportunity to the assessee in the interest of natural justice to represent the case properly by producing

ITA No.790/Chny/2026 Santhanakrishnan Sethunarayanan :- 3 -: the required details. Accordingly, we remit the appeal back to the CIT(A) with a direction to call for necessary details and decide the issue in accordance with law. The assessee is required to submit the necessary details as may be called for and cooperate with the appellate proceedings. It is ordered accordingly.

4.

In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced on 08th day of June, 2026 at Chennai.

Sd/- Sd/- (यस यस िव�ने� रिव) (पदमावती यस) (SS Viswanethra Ravi) (Padmavathy.S) लेखा सद�य लेखा सद�य सद�य /Accountant Member सद�य �याियक �याियक सद�य �याियक �याियक सद�य सद�य / Judicial Member सद�य लेखा लेखा चे�नई/Chennai, �दनांक/Dated: 08th June, 2026. EDN, Sr. P.S आदेश क� �ितिल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकर आयु!/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR 5. गाड� फाईल/GF

Digitally signed by EJTADA DURGA EJTADA DURGA NARESH NARESH Date: 2026.06.11 17:25:49 +05'30'

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